Global Tax Fairness 1st Edition Thomas

Pogge
Visit to download the full and correct content document:
https://textbookfull.com/product/global-tax-fairness-1st-edition-thomas-pogge/
More products digital (pdf, epub, mobi) instant
download maybe you interests ...

International Tax Evasion in the Global Information Age

1st Edition David S. Kerzner

https://textbookfull.com/product/international-tax-evasion-in-
the-global-information-age-1st-edition-david-s-kerzner/

Offshore Finance and Global Governance: Disciplining

the Tax Nomad 1st Edition William Vlcek (Auth.)

https://textbookfull.com/product/offshore-finance-and-global-
governance-disciplining-the-tax-nomad-1st-edition-william-vlcek-
auth/

Global Catastrophic Biological Risks Thomas V. Inglesby

https://textbookfull.com/product/global-catastrophic-biological-
risks-thomas-v-inglesby/

Enterprise Risk Management in the Global Supply Chain

1st Edition Thomas A. Cook

https://textbookfull.com/product/enterprise-risk-management-in-
the-global-supply-chain-1st-edition-thomas-a-cook/
Mastering Global Business Development and Sales
Management 1st Edition Thomas A. Cook (Author)

https://textbookfull.com/product/mastering-global-business-
development-and-sales-management-1st-edition-thomas-a-cook-
author/

Philosophical foundations of tax law 1st Edition

Bhandari

https://textbookfull.com/product/philosophical-foundations-of-
tax-law-1st-edition-bhandari/

The economics of tax policy 1st Edition Auerbach

https://textbookfull.com/product/the-economics-of-tax-policy-1st-
edition-auerbach/

Rightness as Fairness: A Moral and Political Theory 1st

Edition Marcus Arvan (Auth.)

https://textbookfull.com/product/rightness-as-fairness-a-moral-
and-political-theory-1st-edition-marcus-arvan-auth/

The origins of fairness : how evolution explains our

moral nature 1st Edition Baumard

https://textbookfull.com/product/the-origins-of-fairness-how-
evolution-explains-our-moral-nature-1st-edition-baumard/
GLOBAL TAX FAIRNESS
Global Tax Fairness

Edited by
THOMAS POGGE AND KRISHEN MEHTA

1
 3
Great Clarendon Street, Oxford, OX2 6DP,
United Kingdom
Oxford University Press is a department of the University of Oxford.
It furthers the University’s objective of excellence in research, scholarship,
and education by publishing worldwide. Oxford is a registered trade mark of
Oxford University Press in the UK and in certain other countries
© the various contributors 2016
The moral rights of the authors have been asserted
First Edition published in 2016
Impression: 1
All rights reserved. No part of this publication may be reproduced, stored in
a retrieval system, or transmitted, in any form or by any means, without the
prior permission in writing of Oxford University Press, or as expressly permitted
by law, by licence or under terms agreed with the appropriate reprographics
rights organization. Enquiries concerning reproduction outside the scope of the
above should be sent to the Rights Department, Oxford University Press, at the
address above
You must not circulate this work in any other form
and you must impose this same condition on any acquirer
Published in the United States of America by Oxford University Press
198 Madison Avenue, New York, NY 10016, United States of America
British Library Cataloguing in Publication Data
Data available
Library of Congress Control Number: 2015943022
ISBN 978–0–19–872534–3 (hbk)
978–0–19–872535–0 (pbk)
Printed in Great Britain by
Clays Ltd, St Ives plc
Links to third party websites are provided by Oxford in good faith and
for information only. Oxford disclaims any responsibility for the materials
contained in any third party website referenced in this work.
 Table of Contents

List of Figures vii

List of Tables ix
List of Contributors xi

Introduction: The Moral Significance of Tax-Motivated Illicit

Financial Outflows 1
Thomas Pogge and Krishen Mehta
1. Building Institutions for a Globalized World: Automatic
Information Exchange 14
Itai Grinberg
2. Let’s Tax Anonymous Wealth! A Modest Proposal to Reduce
Inequality, Attack Organized Crime, Aid Developing Countries,
and Raise Badly Needed Revenue from the World’s Wealthiest
Tax Dodgers, Kleptocrats, and Felons 31
James S. Henry
3. Country-By-Country Reporting 96
Richard Murphy
4. Hanging Together: A Multilateral Approach to Taxing
Multinationals 113
Reuven S. Avi-Yonah
5. Stateless Income and its Remedies 129
Edward D. Kleinbard
6. The Arm’s Length Standard: Making It Work in a 21st-Century
World of Multinationals and Nation States 153
Lorraine Eden
7. The Taxation of Multinational Enterprises 173
Lee Corrick
8. More Than Just Another Tax: The Thrilling Battle over the
Financial Transaction Tax: Background, Progress, and Challenges 204
Peter Wahl
9. Towards Unitary Taxation: Combined Reporting and
Formulary Apportionment 221
Sol Picciotto
vi Table of Contents

10. An International Convention on Financial Transparency 238

Harald Tollan
11. Lakes, Oceans, and Taxes: Why the World Needs a
World Tax Authority 251
Vito Tanzi
12. Tax Competitiveness—a Dangerous Obsession 265
Nicholas Shaxson and John Christensen
13. A Fair Deal in Extractives: The Company Profit-related Contract 298
Johnny West
14. Self-Help and Altruism: Protecting Developing Countries’
Tax Revenues 316
Michael C. Durst
15. Ten Ways Developing Countries Can Take Control of their
Own Tax Destinies 339
Krishen Mehta and Erika Dayle Siu

Index 357
 List of Figures

2.1 Roots of the 2008 global banking crisis 42

2.2 Top corporate income tax rates by country, 1981–2012 44
2.3 US corporate profits as a percentage of GDP vs US corporate
taxes as a percentage of reported corporate profits 1946–2013 45
2.4 Total US tax receipts/GDP (%) period medians, 1950–2012 46
2.5 “The Debt Hoax,” The New Republic, April 14, 1986 47
2.6 Total fines, settlements, and other legal costs, global financial
services industry 1998–2014 ($bn) 65
2.7 Regulatory penalties vs legal settlements, global financial
services industry, 1998–2014 ($bn) 66
2.8 Total assessments for corporate crimes by offense and bank,
1998–2014 ($bn) 67
2.9 In the present, we will . . . 68
2.10 Top 22 global banks: penalties vs cash flow 71
2.11 Global haven industry: cash flow vs penalties, 1998–2014
(22 global haven banks, current $bn) 72
2.12 Cash flow ($bn) vs penalties ($bn), major banks 1998–2014 73
2.13 Cash flow ($bn) vs penalties ($bn), major banks 1998–2014 74
2.14 Profit rate vs penalty rate, 22 global banks, 1998–2014 75
2.15 Profit rates vs penalty rates, 1998–2014 76
2.16 Top 8 Latin American source countries 82
2.17 Global flight wealth—key source countries, including
China (2010, $bn) 83
2.18 Unrecorded net capital outflows from Latin America, 1970–2010 84
2.19 New unrecorded capital outflows and imputed offshore
earnings as a percentage of GNI, 1976–2009 (real value of
cumulative net outflows by period, 2000 $bn) 86
12.1 Median statutory corporate tax rates, by country income group,
1980–2010 269
12.2 US corporate profits before tax to GDP, 1980–2013 270
12.3 Sources of US federal tax revenue, 1945–2014 271
12.4 Average government revenue and score of the Global
Competitiveness Index 2012–13 285
 List of Tables

2.1 Top 50 global private banks, 2005–10 49

2.2 Top 22 global private banks: Incidence of corporate crime, 1998–2014 57
2.3 Penalties and settlement costs, global banks, 2014 (a) 59
2.4 Penalties and settlement costs, global banks, 2014 (b) 60
2.5 Penalties and settlement costs, global banks, 2014 (c) 61
2.6 Penalties and settlement costs, global banks, 2014 (d) 63
2.7 Global private banking industry: Does crime pay? 70
2.8 Offshore financial assets, high-net-worth individuals 80
2.9 Global distribution, net financial assets 2010 82
2.10 Unrecorded capital flows, offshore assets, and offshore earnings,
1970–2010 85
2.11 Real cumulative offshore earnings vs real cumulative capital outflows,
by region 1970–2010 86
7.1 Timeline: September 2014 181
7.2 Timeline: September 2015 182
7.3 Timeline: December 2015 183
 List of Contributors

Reuven S. Avi-Yonah is the Irwin I. Cohn Professor of Law and Director of

the International Tax LLM Program at the University of Michigan Law
School. He teaches the basic course on taxation and courses on international
taxation, corporate taxation, tax treaties, and transnational law. He has pub-
lished numerous articles on domestic and international tax issues, and is the
author of Global Perspectives on Income Tax Law (Oxford University Press,
2011) and International Tax as International Law: U.S. Tax Law and the
International Tax Regime (Cambridge University Press, 2007). Professor
Avi-Yonah graduated summa cum laude from the Hebrew University in
1983, received a PhD in history from Harvard University in 1986, and received
a JD magna cum laude from Harvard Law School in 1989. From 1989 to 1993
Professor Avi-Yonah practiced tax law in Boston and New York, specializing
in the international tax aspects of mergers and acquisitions. He has served as
consultant to the US Treasury and the OECD on tax competition issues, and
has been a member of the executive committee of the New York State Bar
Association Tax Section and of the Advisory Board of Tax Management, Inc.
He is currently a member of the Steering Group of the OECD International
Network for Tax Research and Chair of the AALS Tax Section, an Inter-
national Research Fellow of the Oxford University Centre for Business Tax-
ation, a Trustee of the American Tax Policy Institute, and a member of the
American Law Institute.
John Christensen has worked in offshore finance and between 1987 and 1998
served as economic adviser to the government of the British Channel Island of
Jersey—a major tax haven satellite of the City of London. Since 2004 he has
directed the global activities of the Tax Justice Network, a leading global
network of experts with a research and advocacy focus on tax havens, tax
avoidance, and tax wars between nations engaged in beggar-thy-neighbor tax
policies.
Lee Corrick is Senior Advisor to the OECD Tax and Development Pro-
gramme working on transfer-pricing capacity-building in developing coun-
tries, particularly in Africa. He is also Technical Adviser on transfer pricing to
the African Tax Administration Forum (ATAF) and an associate lecturer in
international tax at the School of Advanced Study, University of London. Lee
previously worked as the Senior Specialist for Transfer Pricing at the South
African Revenue Service (SARS) and advised National Treasury on changes to
the South African transfer-pricing and thin capitalization legislation. Lee was
also South African delegate to OECD Working Party 6. Before working for
xii List of Contributors

SARS Lee was Assistant Director for Transfer Pricing at HM Revenue and
Customs (HMRC) in the UK with responsibility for HMRC’s transfer pricing
including its litigation work. He led HMRC’s work on its largest and most
complex transfer-pricing disputes and led the HMRC litigation of the DSG
Retail Ltd transfer-pricing dispute. He had responsibility for HMRC’s transfer-
pricing Mutual Agreement Procedure cases and for the HMRC Advanced
Pricing Agreement Programme. He also led the UK delegation at OECD
Working Party 6 and was a member of the Working Party 6 Bureau.
Michael C. Durst has been an attorney for more than thirty years; he has
taught and written widely in the field of international taxation, with a special
interest in problems of developing countries. BA 1975 Williams College; MS
(Econ.) 1978 M.I.T.; JD 1981 U.C. Berkeley; LLM 1985 Harvard.
Lorraine Eden is Professor of Management and Mays Research Fellow at
Texas A&M University, College Station, Texas. She has a PhD with distinction
in economics from Dalhousie University. Her research focuses on two areas:
the economics of transfer pricing and multinational (MNE) strategies in “hot
spots” (e.g., conflict zones, corrupt economies, tax havens). She was editor-in-
chief of the Journal of International Business Studies for 2008–10. She was
elected a Fellow of the Academy of International Business in 2004, and
received the President’s Award from the Academy of International Business
in 2012.
Itai Grinberg joined the Georgetown Law Faculty after serving in the Office of
International Tax Counsel at the United States Department of the Treasury. At
Treasury, he represented the United States on tax matters in multilateral
settings, negotiated tax treaties with foreign sovereigns, had responsibility
for a wide-ranging group of cross-border tax regulations, and was involved
in international tax legislative developments. Prior to joining Treasury, he
practiced tax law at Skadden, Arps, Slate, Meagher & Flom LLP, where he
focused on a wide range of international tax controversy and planning mat-
ters. In 2005, Professor Grinberg served as Counsel to the President’s Advisory
Panel on Federal Tax Reform, where he advised a bipartisan presidential
commission that made sweeping proposals to restructure the US tax code.
Professor Grinberg earned his BA from Amherst College and his JD from Yale
Law School.
James S. Henry is a US economist, attorney, and investigative journalist who
has written extensively about global banking, debt crises, tax havens, and
economic development. In the corporate world, Henry served as Chief Econo-
mist, McKinsey & Co. (NYC global HQ); VP Strategy, IBM/Lotus Develop-
ment Corporation (Cambridge); Manager, Business Development, the
Chairman’s Office (Jack Welch), GE (Fairfield); and Senior Consultant, Moni-
tor Group, the international consulting firm. As Managing Director of Sag
 List of Contributors xiii

Harbor Group, a strategy consulting firm, his clients have included such
enterprises as ABB, Allen & Co., AT&T, AT Kearney, Calvert Fund, Ce-
mex, ChinaTrust, the Scotland Yard/FBI Task Force on Caribbean Havens,
IBM/Lotus, Intel, Interwise, Lucent, Merrill Lynch, South Africa Telkom,
Rockefeller Foundation, the Swedish Power Board, TransAlta, UBS Warburg,
Volvo, and Monitor Company. A member of the New York Bar, he has served
as a pro bono cooperating attorney for the NYCLU on First Amendment
issues, and as Vice President, New York Civil Liberties Union—Suffolk
County. He is author of the acclaimed investigative economics book The
Blood Bankers, and his articles and citations have appeared in The New York
Times, The Wall Street Journal, New Republic, The Nation, The Conference
Board, The Washington Post, Harper’s Magazine, Fortune, Jornal do Brasil,
Manila Chronicle, La Nación, and many others.
Edward D. Kleinbard is the Ivadelle and Theodore Johnson Professor of Law
and Business at the University of Southern California Gould School of Law,
and a fellow at The Century Foundation. Professor Kleinbard joined USC
Gould in 2009. Before joining USC Gould, Professor Kleinbard served as chief
of staff of US Congress’s Joint Committee on Taxation. The JCT staff are the
nonpartisan tax resource to Congress, helping legislators to formulate legisla-
tion, writing analyses of legislative proposals or tax issues of interest to the
Congress, and estimating the revenue consequences of legislative proposals.
Prior to his appointment to the staff of the Joint Committee on Taxation,
Kleinbard was for over twenty years a partner in the New York office of Cleary
Gottlieb Steen & Hamilton LLP. Professor Kleinbard received his JD from Yale
Law School, and his MA in history and BA in medieval and renaissance
studies from Brown University.
Krishen Mehta completed his thirty-year career with Pricewaterhouse
Coopers in 2008 having served in its New York, London, and Tokyo offices.
While at PricewaterhouseCoopers, he was responsible for PwC’s US tax
practice in Japan, Singapore, Malaysia, Taiwan, Korea, China, and Indonesia,
and worked with over 140 American companies conducting business in Asia.
Krishen is currently an advisor to Aspen Institute’s Business and Society
Program, and is a member of the Asia Advisory Council of Human Rights
Watch. He is also a Trustee of the Korbel School of International Studies at the
University of Denver, and of the Institute of Current World Affairs in Wash-
ington, DC. Krishen has taught at a number of universities, including Ameri-
can University and the Fletcher School of Law and Diplomacy at Tufts
University in Boston. He has been an invited speaker at the Global Justice
Program at Yale University, and has conducted Capstone workshops for
graduate students at the School of International and Public Affairs at Colum-
bia University. From 2010–12, Krishen was Co-Chairman of the Advisory
Board of Global Financial Integrity, a division at the Center for International
Policy in Washington, DC.
xiv List of Contributors

Richard Murphy is a UK chartered accountant. He was senior partner of a

practicing firm and director of a number of entrepreneurial companies before
becoming one of the founders of the Tax Justice Network in 2002. He now
directs Tax Research UK and writes, broadcasts, and blogs extensively, the
latter at <http://www.taxresearch.org.uk/Blog/>. Richard created the country-
by-country reporting concept and has been credited with creating much of the
debate on tax gaps in the UK and Europe. He also defined the term “secrecy
jurisdictions,” now widely used in debates on offshore. Richard was named the
seventh most influential person in international tax by the International Tax
Review in 2013.
Sol Picciotto has been a professor at Lancaster University since 1992 (emeritus
since 2007), previously taught at the University of Dar es Salaam (1964–8) and
Warwick University (1968–92), and Scientific Director, the Oñati Internation-
al Institute for the Sociology of Law (2009–11); founding editor and editorial
board member of Social & Legal Studies since 1992; Senior Adviser, Tax Justice
Network since 2003; member of the Advisory Group of the International
Centre for Tax and Development at Sussex University, and coordinator of
its research program on Unitary Taxation with Special Reference to Develop-
ing Countries (2013–14), and Applying International Corporate Tax Reforms
in Developing Countries (2014–15).
Thomas Pogge received his PhD in philosophy from Harvard and is now
Leitner Professor of Philosophy and International Affairs and founding Dir-
ector of the Global Justice Program at Yale. He holds part-time positions at
King’s College London and the Universities of Oslo and Central Lancashire.
Pogge is a member of the Norwegian Academy of Science as well as President
of Academics Stand Against Poverty (ASAP), an international network aiming
to enhance the impact of scholars, teachers, and students on global poverty,
and of Incentives for Global Health, a team effort toward developing a
complement to the pharmaceutical patent regime that would improve access
to advanced medicines for the poor worldwide (http://www.healthimpactfund.
org). Pogge’s recent publications include Politics as Usual (Polity, 2010),
World Poverty and Human Rights (Polity, 2008), John Rawls: His Life and
Theory of Justice (Oxford University Press, 2007), and Freedom from Poverty
as a Human Right (Oxford University Press and UNESCO, 2007).
Nicholas Shaxson is a writer and researcher who has specialized in the oil-
producing countries of West Africa and, more recently, on international
financial centers and tax havens. He is author of the critically acclaimed
Treasure Islands, and has written regularly for the Financial Times, The
Economist, Vanity Fair, Reuters and many others.
Erika Dayle Siu is a tax research consultant and has worked for the United
Nations and the International Centre for Taxation and Development. Her
 List of Contributors xv

research with the UN Tax Committee focused on proposing recommenda-

tions for the UN Model Convention on the taxation of profits from emissions
trading. At the UN Office for South–South Cooperation, Erika worked on a
project to exchange successful tax practices among developing country tax
administrations. Her most recent work with the ICTD analyzes unitary
taxation approaches with a focus on developing country regional economic
communities. Erika is a graduate of New York University Law School’s
Graduate Tax Program and member of the New York Bar.
Vito Tanzi received his PhD from Harvard and was Professor of Economics
at American University (1967–74). He was Chief of Tax Policy Division
(1974–81) and Director of the Fiscal Affairs Department (1981–2000) at the
IMF. Professor Tanzi was Senior Associate at Carnegie Endowment for Peace,
State Secretary for Economy and Finance in the Italian Government (2001–3),
and Senior Consultant to the Inter-American Development Bank. In 1990–4
Professor Tanzi was President of the International Institute of Public Finance,
which has its secretariat at the University of Munich. Author of about twenty
books and of hundreds of articles in professional journals, he has an economic
effect, the “Tanzi effect,” named after him.
Harald Tollan is Senior Advisor in the Norwegian Ministry of Foreign Affairs,
with a focus on development, financial transparency, tax, and natural resource
governance. Tollan chaired the International Task Force on the Development
Impact of Illicit Financial Flows, leading to the establishment of the Financial
Transparency Coalition. Amongst a range of transparency initiatives he has
served on the International Board of the Extractive Industries Transparency
Initiative and as a technical advisor to the African High Level Panel on Illicit
Financial Flows. Tollan is an economist by profession and has worked on
international issues for twenty years in the Norwegian Ministry of Justice, the
Norwegian Agency for Development Cooperation, and the Ministry of For-
eign Affairs.
Peter Wahl studied political economy, sociology, and roman languages in
Mainz, Frankfurt, and Aix en Provence. From 1977 to 1989 he worked as
Secretary General of the German Solidarity Committee for Africa, Asia, and
Latin America, based in Frankfurt dealing with North–South relations. From
1990 to 1993 he was coordinator of the European NGO-network ANPED
(Alliance of Northern People for Environment and Development). In 1990 he
was co-founder of the German NGO World Economy, Ecology & Develop-
ment Association based in Berlin. In 2000 he took the initiative to set up Attac
Germany and served as member in its federal leadership until 2007. Today he
is chairman of World Economy, Ecology & Development Association in
Berlin.
xvi List of Contributors

Johnny West is the founder of OpenOil, a Berlin-based publisher. He has a

Shuttleworth Foundation fellowship to explore the potential of open data
systems to improve accountability and management of extractive industries
worldwide. In 2012 he convened a group to write the first book explaining
petroleum contracts to the general public which has been downloaded 75,000
times. He has advised the United Nations, development agencies, govern-
ments, and civil societies in over twenty countries on extractives governance
issues. Johnny West was a Classics scholar at Balliol College, Oxford and
covered oil markets as a correspondent for Reuters in the Middle East. He
speaks Arabic and Farsi, as well as French and Spanish.
 Introduction
The Moral Significance of Tax-Motivated
Illicit Financial Outflows

Thomas Pogge and Krishen Mehta

New Year’s Day 2016 marks the beginning of the era of the Sustainable
Development Goals, which are to guide development efforts until 2030. It
also marks the expiration of their predecessors, the Millennium Development
Goals (MDGs), which have been used to track progress against human
deprivation over the period of 1990–2015. Although some MDGs will not be
achieved globally and none will be achieved for all countries and regions, there
has been significant human development, especially in China. And yet, incomes
in the poorest three deciles of humanity remain quite low indeed—ranging up
to the purchasing power equivalent, per person per month, of about $60 in the
United States in 2005 (PovcalNet, n.d.). At such low incomes, we cannot be
surprised to find how precarious the human rights of the world’s poor still are.
Of the 7.3 billion people alive today, 805 million are officially counted as
chronically undernourished (FAO, IFAD, and WFP, 2014: 8, 11, 40), well
over 1 billion as lacking adequate shelter (Rolnik, 2014: 1), 748 million as
lacking safe drinking water (Too-Kong, 2014: 47), 1.8 billion as lacking ad-
equate sanitation (Too-Kong, 2014: 25), around 1.1 billion as lacking electricity
(World Bank, n.d.), more than one-third as lacking reliable access to essential
medicines (Nyanwura and Esena, 2013: 208), 781 million over age 14 as illiterate
(UNESCO, 2014), and 168 million children (aged 5 to 17) as doing wage work
outside their household—often under slavery-like and hazardous conditions: as
soldiers, prostitutes, or domestic servants, or in agriculture, construction, textile
or carpet production (ILO, n.d.). During the first decade of the new millennium,
easily a third of all human deaths were due to poverty-related causes, some
50,000 daily (WHO, 2008: 54–9 Table A1).1 For the entire decade, severe poverty

1
The figure in the text is derived by counting deaths from causes that occur almost exclusively
in the poor countries, such as diarrhoeal diseases, hepatitis, HIV/AIDS, lower respiratory
2 Thomas Pogge and Krishen Mehta

killed at least 180 million people, three times as many as perished in the Second
World War.
Severe deprivations suffered by so many people constitute a massive deficit
in social and economic human rights as summarized in Article 25(1) of the
1948 Universal Declaration of Human Rights: “Everyone has the right to a
standard of living adequate for the health and well-being of himself and of his
family, including food, clothing, housing and medical care and necessary
social services, and the right to social security in the event of unemployment,
sickness, disability, widowhood, old age or other lack of livelihood in circum-
stances beyond his control.” But these same deprivations also entail massive
deficits in civil and political human rights. Very poor people are substantially
more vulnerable to violence, for instance, because they lack the protection of a
secure home and because others—including police and other state officials—
can with impunity ignore their needs and even mistreat them. Severely
deprived people also are generally poorly equipped to fend for their legal
rights and interests: many of them are physically or mentally stunted due to
malnutrition in infancy, many are poorly educated or even illiterate, and most
are in addition heavily preoccupied with their family’s survival and thus find it
very hard to defend, individually or collectively, their legal rights to political
participation and due process. Especially in rural areas but also in relation-
ships of domestic service, employers, landowners or local officials find it easy
to entrap poor people—often from an early age—in relations of abject servi-
tude and personal dependence, which in turn perpetuates their poverty, often
over generations.
In centuries and decades past, most human deprivation may have been
unavoidable. In more recent times, however, humanity has quite clearly come
to possess the economic, technological, and administrative capacities to avoid
such severe poverty. Just consider the current distribution of global household
income: the poorest three quarters of humanity have merely 15 percent, the
poorest half have 4.4 percent and poorest quarter 1.22 percent.2 Global wealth
inequalities are even more dramatic, with the 66 richest people on Earth
owning as much wealth—0.6 percent—as the poorer half of humanity
(Moreno, 2014).3 Surely we could implement institutional reforms that
would raise the share of the poorer half enough at least to realize their
human rights. If this required raising their income share from 4.4 percent to
7 percent, and if this raise came entirely at the expense of the richest ventile’s

infections, malaria, maternal conditions, measles, meningitis, nutritional deficiencies, perinatal

conditions, pertussis, tropical-cluster diseases, and tuberculosis.
2
These 2011 data on the distribution of global household income at market exchange rates
were kindly provided by Branko Milanovic, City University of New York.
3
The webpage concludes with a later update saying that the wealthiest 66 people now suffice
to match the wealth of the poorer half.
 Introduction: The Moral Significance of Tax-Motivated Outflows 3

income share, these richest 5 percent of humanity would still capture over 40
percent of global household income.4
The foregoing reflections alert us to the obvious point that development
efforts are not the only factor affecting the evolution of the global income
distribution. These efforts are, in fact, of comparatively minor significance:
easily overwhelmed by stronger opposing forces that favor the most affluent
segment of humanity and disfavor the world’s poor. Prominent among these
opposing forces are structural features of the existing global economic and
financial order which, shaped under the influence of the more powerful
multinational corporations (MNCs) and banks, industry associations, hedge
funds, and billionaires, tends to serve the interests of these powerful agents.
The present volume focuses on the global financial system and, in particu-
lar, on some of its important structural features that facilitate so-called illicit
financial flows, which disproportionately drain the economies and state
budgets of the developing countries. Illicit financial flows are movements
across international borders of funds that are earned or transferred or utilized
in violation of law. Often motivated by the desire, and followed by the result,
of avoiding taxes, duties, and other fees, such flows severely diminish govern-
ment revenues in poor countries and also deprive these countries of much-
needed capital. The present volume offers a set of essays that analyze various
aspects of this phenomenon and discuss plausible reform ideas. It is our shared
hope that these discussions will contribute to the success of ongoing efforts—
in the OECD, the G7 and the G20, for example, as well as within countries and
regional groupings of countries—to curtail illicit financial flows and will also
help ensure that these efforts are responsive to the needs and interests of the
poorer countries.5
The first-line responsibility for poverty-related human rights deficits lies
with the governments of the countries in which severe poverty persists. But
most of these governments are also poor. While the advanced industrialized
states have annual government revenues in the order of $20,000 to $50,000 per
person, India has annual revenues of barely $200 per person and many other
governments are poorer still. These large international discrepancies are due
to two factors: the per capita gross domestic products of poor countries are
much smaller; and these countries also raise a much smaller proportion of
their gross domestic products (GDPs) as government revenues, typically
below 20 percent as compared to an OECD average of well over 40 percent.
It is difficult for poor-country governments to raise income or consumption
taxes from the poor majority of their population—such taxes are unpopular,
costly to collect and aggravate the very human rights deficits they are supposed

4
According to Milanovic, the richest ventile captured 42.8% of global household income
in 2011.
5
A valuable predecessor to our volume is Reuter (2012).
4 Thomas Pogge and Krishen Mehta

to alleviate. But such governments also encounter difficulties in imposing taxes

on those who could pay. Through sophisticated efforts, wealthy citizens of
these countries, and corporations operating there, escape taxation to an extent
that would be unthinkable in an affluent country with political clout and a
highly sophisticated and well-funded tax administration. Boston Consulting
Group estimates that 33.3 percent of all private financial wealth owned by
people in Africa and the Middle East and 25.6 percent of such wealth owned
by Latin Americans—some $2.6 trillion in total—is kept abroad; while the
analogous estimates for North America and Europe are 1.8 percent and 7.9
percent, respectively (Boston Consulting Group, 2013: 4, 11). To collect taxes
on the income and capital gains produced by this wealth, poor countries must
largely rely on the honesty of their taxpayers as they lack access to information
about their citizens’ overseas holdings.
MNCs also reduce their tax burden significantly, typically by creating
additional subsidiaries in tax havens and then having their poor-country
subsidiaries contract with their tax-haven subsidiaries into arrangements
that diminish the taxed profits of the former while increasing the untaxed
profits of the latter—arrangements involving trade misinvoicing, abusive
transfer prices, or inflated consulting or trademark fees, for example
(Hearson and Brooks, 2012). Global Financial Integrity estimates that corpor-
ate tax abuse accounts for 80 percent of all illicit financial outflows from less
developed countries, or about $6.6 trillion during the 2003–12 period and
$991 billion in 2012 alone (Kar and Spanjers, 2014: vii). These illicit outflows
constitute 3.9 percent of the GDP of the developing countries (5.5 percent in
Africa) (Kar and Spanjers, 2014: 11), are larger than incoming total foreign
direct investment (Kar and Spanjers, 2014: 12) and also vastly larger than the
sum total of all official development assistance flowing into these countries,
which officially amounted to some $127 billion in 2012 (UN, n.d). Christian
Aid calculates that, through these profit- and tax-diminishing capital outflows,
governments of less developed countries have lost tax revenues in the order of
$160 billion annually—or about $2.5 trillion for the 2000–15 period. “If that
money was available to allocate according to current spending patterns, the
amount going into health services could save the lives of 350,000 children
under the age of five every year” (Christian Aid, 2009: 3).6
Clearly, massive reductions in existing human rights deficits could be
achieved by allowing poor countries to collect reasonable taxes from MNCs
and from their own most affluent nationals, assuming the resulting revenues

6
Intense national and international efforts are underway toward improving current govern-
ment spending patterns in poor countries, which are often distorted by corruption, bloated
security apparatuses, and indifference to the poor. Insofar as such efforts are succeeding,
additional revenues would have an even larger human rights impact than Christian Aid is
calculating.
 Introduction: The Moral Significance of Tax-Motivated Outflows 5

were appropriately spent.7 One might fault various groups of agents for poor
countries’ current inability to do so and for the resulting human rights deficit.
There are the secrecy and tax haven jurisdictions (including Switzerland,
Ireland, the UK, and the US) that structure their tax and legal systems so as
to encourage tax abuse and also typically protect bank secrecy against the tax
authorities of less developed countries. There are the individuals and corpor-
ations who erode the tax base of poor countries by using tax havens to dodge
or reduce taxes on their wealth and profits. And there are many bankers,
lawyers, accountants, and lobbyists who devise, implement, and “legalize”
these schemes. Moreover, the jurisprudence of the European Court of Justice
has made it difficult for countries in the largest integrated economic area on
Earth to enact legislation to address some of these concerns. While all these
agents surely share responsibility, it is quite unrealistic to hope that the
problem can be meaningfully reduced through their morally motivated self-
restraint. Even if many of them could be convinced to desist, their business
would continue to thrive so long as it provides attractive and safe rewards.
Realistically, tackling the problem of illicit financial outflows from the poor
countries requires concerted action on the part of the more powerful rich-
country governments, which currently all too often encourage the tax dodging
of their MNCs abroad8 and use strong-arm tactics to get tax havens to
cooperate with their own tax enforcement efforts without ensuring that
poor-country governments receive similar cooperation.9
The current draft of the Sustainable Development Goals agrees that we
should “by 2030 significantly reduce illicit financial and arms flows” (Open
Working Group for Sustainable Development Goals, 2014: Target 16.4). But it
falls miserably short of recognizing what the most powerful states within the

7
See also International Bar Association (2013).
8
Shifting profits out of developing countries would not be so lucrative for MNCs, if their
home countries taxed such profits while granting a tax credit for profit taxes already paid abroad.
But most such home countries do not do this, allowing MNCs to pocket the taxes they dodge in
poor countries as pure profit. The US is an exception by imposing a 35% tax on funds that MNCs
repatriate from tax havens while granting a tax credit for taxes already paid abroad. But there are
ways of getting around this tax. Thus the US Congress granted a “tax holiday”—misleadingly
named the American Jobs Creation Act of 2004, which temporarily enabled US-based MNCs to
repatriate profits accumulated in tax havens at a discounted 5.25% tax rate (Alexander, Mazza,
and Scholz, 2009: 401–57). A coalition of 93 corporations spent $282.7 million on a concerted
effort to get this Act passed by the US Congress, and these same corporations then repatriated
over $200 billion while realizing a total of $62.5 billion in tax savings—$221 for every $1 they had
invested in lobbying. The losses fell mostly on the populations of the less developed countries
from which these MNCs had shifted their profits into tax havens; without the prospect of
circumventing profit taxes in their home country, MNCs would have little to gain from such
profit shifting.
9
Even the OECD’s new landmark model agreement on automatic exchange of financial
information is likely to exclude many less developed countries from its benefits because they lack
the resources to set up the data collection arrangements required to qualify as a reciprocating
partner.
6 Thomas Pogge and Krishen Mehta

global financial system would need to do in order to accomplish this task. All
the Open Working Group (OWG) draft demands of them is that they
“strengthen domestic resource mobilization, including through international
support to developing countries to improve domestic capacity for tax and
other revenue collection” (Open Working Group for Sustainable Development
Goals, 2014: Target 17.1).
The key to reducing the tax gap and consequent human rights deficit in the
poor countries is global financial transparency: the abolition of shell compan-
ies and anonymous accounts, automatic exchange of tax information world-
wide, and the requirement that, in their audited annual reports and tax
returns, MNCs report their sales, profits, and taxes paid country by country
for each jurisdiction in which they operate.10 Adding such targets to the SDGs
would open the door for policy reforms that are essential to curbing illicit
financial flows which, by draining less developed countries of capital and tax
revenues, are a great impediment to sustainable development. Such policy
reforms would not merely advance tax justice but would additionally protect
human rights by also curtailing the activities of criminals such as terrorists,
money-launderers, and traffickers in persons, drugs, and weapons.
A major break-through for financial transparency is now within reach. To
achieve it, the citizens of the countries that are home to the world’s major
financial centers must keep up the pressure on their governments to carry
forward the needed institutional reforms and to shape these reforms so that
the populations of the poor countries, whose basic human rights are at stake,
participate fully in their benefits.
Let us now take a quick overview of the chapters that constitute this anthol-
ogy. We start with the more conventional, better-known smaller reforms that
developed countries can implement without a lot of international coordination
and then ascend from there to deeper more systemic reforms that would require
these same countries to build, and then to subject themselves to, substantial
global institutional mechanisms. We then follow a similar approach for the
developing countries, again ascending from smaller, more conventional ideas
to larger and more radical ones.
Itai Grinberg’s chapter proposes a system of Automatic Exchange of Infor-
mation (AEI) that is uniform and multilateral in order to tackle tax evasion
through the use of offshore accounts. This is premised on the role that
financial institutions can play as tax intermediaries to facilitate government-
to-government exchange of tax information. There is precedence for this, as
Grinberg explains in his chapter, and also some progress through the
OECD. But creating a uniform multilateral automatic information exchange
system that benefits the developing countries that need it most, and not just

10
Extensively discussed in the present volume, these are among the key ideas emerging from
a recent Delphi study conducted by Academics Stand Against Poverty (ASAP, 2014).
 Introduction: The Moral Significance of Tax-Motivated Outflows 7

the major developed economies, requires much more intensive investment in

institutions as well as a refined technical architecture. Developing countries
should have a stronger voice in the substance of the information exchange,
which should not be controlled on a selective basis by the developed countries
that are the recipients of much of the developing countries’ wealth. The overall
objective of information exchange also requires continuing progress on prac-
ticable mechanisms for identifying beneficial owners of financial accounts.
Jim Henry’s reform proposal is startling in its simplicity. Very simply, he
argues for taxing anonymous wealth at a modest rate of 0.5 percent per
annum. This would only be for accounts that prefer to remain private, and
where the beneficial owner is not publicly known or disclosed by choice of the
true owner. Much of this money is now invested by way of the burgeoning
global tax haven industry. The levy would be administered by the financial
institutions and could generate billions of dollars each year. An international
trust fund can then be created to channel this revenue directly to valuable
projects, like helping poor countries adapt to climate change, recover from
so-called natural disasters, prepare for epidemics, deploy the infrastructure
required for clean water and smarter power grids, lower the outrageous fees
they now pay for remittances and finance, and backstop the First World’s
shrinking budgets for development aid.
Richard Murphy’s chapter proposes a reform of the current corporate
accounting practices and converging to a country-by-country reporting
model. This would require multinational corporations to report their profits
and losses in every jurisdiction where they operate rather than providing one
consolidated balance sheet for all operations. The current system enables
companies to use tax havens and hide abuse of the arm’s length pricing
method of transfer pricing, thereby reducing the amount of tax they owe in
both developed and developing countries. Country-by-country reporting
would provide an accurate picture of actual corporate performance in each
jurisdiction, would bring transparency to the incentives or treaty benefits that
have been agreed and would empower institutional investors and civil society
to have credible information on the true corporate performance. The inevit-
able consequence of this would be a more equitable tax system that would be
fair to all jurisdictions.
Reuven Avi-Yonah proposes doing away with tax deferrals in their entirety.
His chapter proposes that each OECD member country impose a tax at its
normal corporate rate on the entire profit of multinationals that are managed
and controlled from headquarters within it, with a foreign tax credit allowed
for taxes paid to other jurisdictions. An approach such as this would reduce
tax competition among countries and also diminish the propensity of MNCs
to keep offshore trillions of dollars that are not subject to current taxation.
This proposal offers an important and thoughtful solution to the faults of the
current system, which is widely seen as conducive to massive tax avoidance.
8 Thomas Pogge and Krishen Mehta

The proposal treats the multinational corporation in the same way it is treated
for financial reporting purposes—as a single unified entity controlled by the
parent. In the modern world, this is a much more realistic and equitable
approach to taxation, in comparison to taxing each entity separately and
allowing profits to be deferred.
Edward Kleinbard’s proposal argues for a fundamental reform of international
tax norms that produce stateless income, that is, income that is earned by MNCs
but not taxable in any jurisdiction. The stateless income phenomenon is large
and amounts to lost tax revenues in excess of $100 billion each year to both
developed and developing countries. It leads to government budget shortfalls,
and it distorts a multinational firm’s incentives as to where to invest as an
economic matter. Options considered as solutions by Kleinbard include formu-
lary apportionment—where a corporation’s global profit is divided up and
attributed to each jurisdiction where it has a taxable presence based on specific
(economic?) factors, and taxed accordingly. Another option is to limit territorial
tax models, under which only source countries tax business arising in those
countries, to cases where it can be convincingly demonstrated that the source
country is the nexus of business income (“geographic nexus”). This would require
more precisely defining geographic nexus in terms of actual business activity.
Kleinbard explains these concepts quite simply and eloquently in his chapter.
Lorraine Eden proposes policies for improving, rather than replacing, the
current Arm’s Length Standard (ALS) in order to limit transfer pricing abuse.
The arm’s length standard is designed to answer the question, “What would
independent enterprises do?” Eden argues that this criterion requires MNCs
and governments to search for arm’s length comparables; a search that is
problematic both in theory and practice. Eden suggests a variety of remedies to
fine-tune the methods and processes currently used to implement the search
for comparables. These remedies, several of which are currently being dis-
cussed as part of the OECD’s BEPS initiative, would eliminate most of the
incentives for abusive behavior that riddle the international tax system today.
Lee Corrick’s chapter takes us into the real world of reforms currently under
discussion among governments and within the relevant international agencies,
and how this is a global issue requiring global solutions. He provides an update
on the OECD’s Base Erosion and Profit Shifting (BEPS) project, its genesis and
the progress made thus far. At the core of BEPS is the premise that inter-
national tax rules have not kept pace with the changing business environment
and that urgent action is needed to correct the resulting distortions. The paper
discusses the current fault lines in the international tax system, the action
plans that seek to address them and the solutions and compromises that are
emerging as of this anthology’s date of publication.
Peter Wahl’s reform proposal seeks to rekindle the ongoing debate about a
Financial Transaction Tax (FTT) and supports the proposal made by the
European Commission toward implementing such a tax. This proposal is
 Introduction: The Moral Significance of Tax-Motivated Outflows 9

currently being considered by the European Parliament. The FTT has been
advocated by civil society for years, but it was not until the financial crash of
2008 that the proposal gathered momentum as many policymakers realized
that the current system is not working and that tax evasion is rampant. The
FTT proposal derives additional support from the need to regulate finance as
an instrument of society and to reduce some of the currently existing volatility
in financial markets. In these ways, an FTT would also serve financial institu-
tions as well as society at large. The success of the civil society movement
pushing for an FTT can also serve as a useful example and provide valuable
lessons for other movements.
Sol Picciotto’s chapter proposes reorienting international tax rules so that
multinationals are treated as single firms rather than as a collection of separate
and independent entities. His reform proposal envisions the adoption of a
system of unitary taxation with combined reporting and profit apportionment
for multinational companies. A basic premise in Sol Picciotto’s chapter is that
the current international tax system is so flawed that it is unlikely to be corrected
by applying further patches to the existing rules. What is clearly needed is to
reorient the rules at a more fundamental level, specifically so that multinationals
are treated for tax purposes as single firms rather than as a collection of separate
and independent entities. This idea is known as unitary taxation, and such a
system would have three components: combined reporting for the firm as
a whole, including consolidated worldwide accounts, profit apportionment
(as explained in Kleinbard’s contribution), and a resolution procedure for
resolving conflicts between states. Picciotto argues that such reform would
place international taxation on a much sounder foundation, and would address
most of the egregious tax avoidance practices by multinationals.
Harald Tollan’s chapter proposes the creation of an International Conven-
tion on Financial Transparency that would require countries to modify cur-
rent regulations and practices that facilitate financial secrecy within their own
countries and across international borders. It would provide legally binding
rules for financial transparency, and a framework for strengthening the global
community’s commitment to such transparency. The basic principle under-
lying the Convention is that financial secrecy undermines the sovereignty of
other jurisdictions (their right to collect taxes) and must be addressed head-on
if it is to be abolished over the longer term. Rather than international regula-
tion tolerating the existence of financial secrecy and other harmful structures
and adapt to it, the Convention would address the root cause of the problem
and attempt to do away with secrecy altogether.
Vito Tanzi’s reform proposal argues for the creation of a World Tax
Authority (WTA) that would have the objective of making the tax policies
of a country with global implications a global business and not the exclusive
business of that country alone. A WTA would identify and report on problems
in taxation at the international level and propose solutions. It would also
10 Thomas Pogge and Krishen Mehta

establish a system of monitoring the use of the tax policies of the various
countries to identify egregious practices that cannot be condoned. Vito argues
for a WTA that would be like an influential and competent global mentor that
can work toward the implementation of tax reforms that benefit all countries.
The WTA would provide a forum for discussing tax policies with cross-
countries implications and also serve as a forum for tax disputes for resolving
tax disputes among countries. It would do for the area of taxation what the
World Trade Organization does for the trade area.
The chapter by Nicholas Shaxson and John Christensen addresses the
promotion by many politicians around the world of so-called “tax competi-
tiveness.” It proposes that this ideologically driven phenomenon is reframed as
“tax wars” and suggests a set of recommendations for how developing coun-
tries can respond to such economic warfare. It also argues for the creation of a
think-tank whose mission would be to counteract tax competition as an
ideology, that is, as a belief system that falsely promotes tax competition as a
demand of economic realities. The world understands now that offering tax
incentives to tempt investment, hot money and individual wealth shrinks the
tax base, distorts markets and results in a “race to the bottom” in which
nobody (except for the very richest people) wins. Tax competition has nothing
to do with market competition and is more like a trade or currency war. The
chapter makes a compelling case for ending the race to the bottom since it
harms sustainable development while also undermining democratic govern-
ments and diminishing human rights.
Johnny West’s proposal makes a strong argument for reforming the current
tax structure of oil and mining contracts between companies and govern-
ments. We have all heard of the “resource curse” affecting many developing
countries that benefit little from the wealth extracted from their territories,
wealth that ought to enhance the welfare of all their citizens. West proposes a
new framework for extractive industry contracts directly linking taxation to
the “internal rate of return” used by the companies to measure profitability.
This would result in a more equitable economic return to developing countries
where the extraction is taking place. In many poor (but resource-rich) coun-
tries today, there have been decades of super-profits for extracting companies
and little or no revenue for the citizenry of the countries concerned. This
paradigm is not sustainable over the long term and needs to shift. Johnny
West’s essay provides a solution and a way forward.
Michael Durst takes the position that action is needed in both developed
and developing countries if the goal of tax justice is to be achieved. In the
developed world, there is a clear need for strengthening some of the interna-
tional Controlled Foreign Corporation (CFC) rules—which, roughly, subject
certain kinds of income transferred from a subsidiary to one in a zero-or-low tax
jurisdiction to the MNC’s home country’s tax rate. Developing countries, in
turn, need to take action to limit taxpayers’ ability to move income to zero- and
 Introduction: The Moral Significance of Tax-Motivated Outflows 11

low-tax countries through various kinds of deductible payments, including

interest and excessive payments for goods and services. Developing countries
also should protect their tax bases through more substantial withholding taxes
on deductible payments—an approach with historical precedent but which has
tended to atrophy in recent decades. Durst argues that both the wealthier
countries and developing countries will need to muster greater political will to
take the measures necessary to protect the world’s tax bases. In particular, the
wealthier countries will need to be willing to enforce tax payments by their
home-based multinationals in their competitive activities around the world, and
developing countries will need to be willing to collect taxes effectively from
inbound investors even at the competitive risk of deterring some investment.
Overall, Durst suggests, the key to effective action against base erosion lies more
in the realm of politics, and particularly in countering the forces of tax compe-
tition, than it does in the technical intricacies of tax law.
The final essay by Erika Siu and Krishen Mehta addresses an important and
sensitive issue, that of tax sovereignty. How can developing countries take
control of their own tax destinies and still not risk losing foreign direct
investment? In this paper, Siu and Mehta present ten steps that developing
countries can take, within the existing tax norms and practices, to significantly
improve their tax revenues as a percentage of GDP. These steps include
caution about signing tax treaties, avoiding tax competition and incentives,
adopting safe harbors to simplify tax administration and compliance, adopting
a wider use of the profit split method in determining source country taxation,
adopting more disclosure and attestation rules, taxing the black economy, and
so on. These steps are fully within the developing countries’ control and are
not subject to challenge under international tax laws and practices. It is
therefore important that developing countries not miss these opportunities
while they pursue and support a more just and equitable global tax system.

ACKNOWLEDGMENTS

The editors would like to give special thanks to Esther Shubert, graduate student of
philosophy at Yale University, who has collaborated closely with us on the editorial
tasks and, through her careful and highly competent work, has greatly contributed to
the quality of this volume. In particular, Ms. Shubert has reviewed and commented on
drafts of each chapter, communicated with authors about their chapters and paper-
work, communicated with the OUP editors, formatted the reference sections of the
draft manuscript for compliance with OUP’s style and for consistency (in some cases
creating abstracts and keywords, in some cases providing assistance with reviewing the
copy-edited chapters), obtained copyright permissions for images and figures, and
given useful input on the table of contents, title, and other matters. We have been truly
fortunate to have had such a bright and versatile collaborator.
12 Thomas Pogge and Krishen Mehta

We are deeply grateful also to Norway’s Ministry of Foreign Affairs, to the German
Friedrich Ebert Stiftung, and to Academics Stand Against Poverty for recognizing the
importance of this volume and helping us cover the costs of producing it.

R E F E RE NC E S
Alexander, Raquel M., Stephen W. Mazza, and Susan Scholz, 2009. “Measuring Rates
of Return on Lobbying Expenditures: An Empirical Case Study of Tax Breaks for
Multinational Corporations,” Journal of Law and Policy 25 (4): 401–57.
Academics Stand Against Poverty, 2014. “Policy Options for Addressing Illicit Financial
Flows: Results from a Delphi Study.” <http://academicsstand.org/wp-content/
uploads/2014/09/Policy-Options-for-Addressing-Illicit-Financial-Flows-Results-
from-a-Delphi-Study.pdf> accessed 15 July 2015.
Boston Consulting Group, 2013. Global Wealth 2013: Maintaining Momentum in a
Complex World. <http://www.bcg.de/documents/file135355.pdf> accessed 31
December 2014.
Christian Aid, 2009. “False Profits: Robbing the Poor to Keep the Rich Tax-Free.”
<http://www.christianaid.org.uk/Images/false-profits.pdf> accessed 15 July 2015.
FAO, IFAD, and WFP, 2014. The State of Food Insecurity in the World 2014. Strength-
ening the Enabling Environment for Food Security and Nutrition. Rome, UN Food
and Agriculture Organization.
Hearson, Martin and Richard Brooks, 2012. “Calling Time.” Action Aid. <http://www.
actionaid.org.uk/doc_lib/calling_time_on_tax_avoidance.pdf> accessed 15 July 2015.
ILO, n.d. “Child Labour.” <http://www.ilo.org/global/topics/child-labour/lang–en/index.
htm> accessed 15 July 2015.
International Bar Association, 2013. “Tax Abuses, Poverty and Human Rights”. London.
<http://www.ibanet.org/Human_Rights_Institute/TaskForce_IllicitFinancialFlows_
Poverty_HumanRights.aspx> accessed 15 July 2015.
Kar, Dev and Joseph Spanjers, 2014. “Illicit Financial Flows from Developing Countries:
2003–2012.” Global Financial Integrity. Washington. <http://www.gfintegrity.org/
report/2014-global-report-illicit-financial-flows-from-developing-countries-2003-
2012/> accessed 15 July 2015.
Moreno, Kasia, 2014. “The 67 People As Wealthy As The World's Poorest 3.5 Billion,”
Forbes. 25 March. <http://www.forbes.com/sites/forbesinsights/2014/03/25/the-
67-people-as-wealthy-as-the-worlds-poorest-3-5-billion/> accessed 30 December
2014.
Nyanwura, Edmund Mohammed and Reuben K. Esena, 2013. “Essential Medicines
Availability and Affordability: A Case Study of the Top Ten Registered Diseases in
Builsa District of Ghana,” International Journal of Scientific and Technological
Research 2 (8): 208–19.
Open Working Group for Sustainable Development Goals, 2014. “Outcome Document.”
<http://sustainabledevelopment.un.org/content/documents/4518SDGs_FINAL_
Proposal%20of%20OWG_19%20July%20at%201320hrsver3.pdf> accessed 15 July
2015.
Another random document with
no related content on Scribd:
 “I thought when I opened the drawing-room door that it was
tapestry.”
“The coarse texture of the cloth does in fact resemble the tapestry
stitch, and the painting in distemper has the flat tone of wool. On the
whole, the hangings of our house scarcely cost more than the high-
priced papers that are made now-a-days, and they last longer, to say
nothing of our being sure not to see our own patterns on everybody’s
walls.”
“Very true; often on going into a drawing-room I have recognized a
paper which I had seen elsewhere. But tell me, cousin, you have had
lightning-conductors put up, have you not?”
“Certainly; it was prudent to do so. I have had two constructed:
one at the top of the staircase, and the other on the centre-point of
the main-ridge.”
“Would not one have been enough?”
“I think not; because lightning-conductors only protect the points
inclosed in a cone of which they are the summit: at least, this is the
recognized theory. For between ourselves, physicists are not quite
agreed respecting the effects of the electric fluid, the relative
efficiency of conductors, and the precautions to be used in putting
them up. I rely on my own experience, which has proved to me that
no building, however exposed, has been struck by lightning when the
lightning-rods were numerous, made of good conductors, put in
communication with each other, and with their lower extremity
dipping in water, or very damp earth. You know that water is a
conductor of electricity; if the lightning-rod terminates in dry earth the
electricity accumulates, and produces return shocks, which are very
dangerous. The same effect results if the conducting-wire is
interrupted; the lightning-rod then produces the effect of a Leyden jar
—it becomes charged, and is more dangerous than useful. Sockets
with glass insulators have also been recommended; but I have never
observed that lightning-conductors otherwise well arranged caused
accidents for want of insulators. I consider this precaution
superfluous, because the fluid seeks the most direct path. The rod
properly arranged is that path; so it should not make rapid angular
turns, but as far as possible be conducted by the shortest way, and
that which is nearest the vertical, into the damp soil.”
At dinner nothing was talked about but the new house and
Madame Marie’s arrival. There was a lively discussion about the way
of making the surprise complete. The ceremonial, to which M. de
Gandelau had given some thought, was soon arranged. The
contractors and craftsmen of the neighbourhood who had worked at
the house were invited, and a dinner was to be provided for them in
the garden. The gentleman who had given Paul lessons, the mayor,
the curé of the parish, and some neighbours and friends, among
others M. Durosay, who had again made his appearance in the
neighbourhood, were asked to be present at the house-warming.
The workmen had not been forgotten—they were all to receive some
gratuity. There was to be a ball in the new park for all the country
people, with the customary refreshments; and in the morning the
poor of the parish were to receive gratuities in kind.
Paul was very much afraid that his sister had some inkling of the
intended surprise. He said that if no mention was made of the house,
which had been talked so much of before the war, in the letters
written to Madame Marie, the very silence might appear to her
suspicious.
“He is right,” said Madame de Gandelau. “If Marie asks us what
has become of the project and of the programme she sent, if she
asks us how we have been occupied during the past year, we shall
be obliged to prevaricate considerably. We shall contradict each
other, and I really am rather averse to anything of the sort. We shall
not be able to keep up a mystification for two or three hours together.
Besides, Lucie is sure to let out the secret.”
“Oh, no!” said Lucie; “I shall say nothing, you may be quite sure.”
“Your eyes will speak for you, my dear child. But I will manage the
matter. Leave me alone for a few moments with Marie. I will tell her
that Paul, for the sake of some occupation during his over long
holiday, has been building a small house, with his cousin’s
assistance. I shall allow her to suppose it to be a mere schoolboy’s
fancy. She will think it is only done for amusement—a little building
model, cleverly constructed. We can then talk to her about it without
embarrassment, in a jocular way. Then after dinner we will propose
to her to go and see Paul’s house.”
And so matters were arranged.
Paul slept but little during this night, though he had started very
early from Paris, and had been using—in fact, over-using—his legs
all day.
The 19th of May, 1872, at 9.40, Monsieur and Madame N——
were getting out of the train at X—— Station, where Monsieur de
Gandelau was awaiting them with a new chaise. Twenty minutes
after they were entering the court of the château. We need not dwell
upon the embraces, the transport mingled with tears, that occupied
the first minutes of their return.
Madame de Gandelau had arranged their rooms with all possible
care, as if they were going to make a long stay at the château.
Of course the mother thought her daughter improved; Madame
Marie considered Paul grown—almost a man, in fact, and
Mademoiselle Lucie almost a young woman.
Thanks to Madame de Gandelau, Paul’s house was referred to
during breakfast only as a matter of no importance. The adventures
of travel and the war were talked of. After nearly two years’ absence
subjects of conversation could not be wanting. But Paul was agitated
and absent. His sister remarked it. Paul blushed up to his very eyes.
“I think Paul has some scheme in his head,” said M. N——.
Monsieur and Madame de Gandelau looked at each other, smiling.
“What is in the wind, then,” said Madame Marie; “a conspiracy?”
“Perhaps,” replied Madame de Gandelau; “but let us allow him the
pleasure of carrying it out.”
“Conspire, dearest mother! I will help you with all my heart,” said
Madame de N——, with a smile that expressed archness as well as
affection.
 They could say nothing for the moment of the projected excursion,
for they were on the point of betraying themselves. Madame de
Gandelau wished her daughter to take some rest after her journey.
M. N—— asked leave to despatch some letters that required
immediate attention, and silence reigned again in the château. The
day was hot, and nothing was heard but the buzzing of insects on
the lawns. Paul, however, could not keep quiet.
“You are not a diplomatist yet,” his cousin said to him. “Do, my
dear fellow, remain still. There’s nobody but you stirring in the house.
You will let out the secret if you go on in this way. Go to your room,
take a book—a dull one; you will get to sleep, and the time will pass
away.”
“But what about all the people who have been invited and are
waiting down at the house?”
“Ah!—yes—true. Well, mount your pony, go to the house and tell
all the guests to admire the wonders of the new domain and to have
patience. Say that Madame Marie is a little fatigued, and that she will
not be able to have the pleasure of meeting them till the afternoon.
Then return.”
Paul did not allow this to be repeated, so impossible did rest seem
to him. He would have given at this moment ten years of his life to
make his sister resolve to get into the carriage.
Fig. 62.
 It is impossible to say what the pony thought of the pace Paul
made him go, at a temperature of 77° Fahr. in the shade. He arrived
in a foam at the new house, so that most of the persons already
assembled suspected that some accident had happened. When
Paul, quite out of breath, told them that Madame Marie had put off
her visit for an hour or two because she wanted rest, they exclaimed,
“If it is only that, there’s no need of any great hurry; it is quite
natural she should need rest after so long a journey.”
Then everyone wanted to hear news of the travellers, and then
they asked Paul to see this and that. Paul was in a fever.
“You are not going to ride back again in this state,” said the mayor;
“you are in a bath of perspiration, and your pony is white with foam.
Rest a little, and drink a glass of wine.”
It would have been discourteous not to comply, for the mayor had
brought a basket of petit vin de Saumur. They drank the health of the
future occupants, and the prosperity of the house, so that Paul lost a
good hour. At last he was able to retrace his road to the château, at
the same rate as before. But on reaching the edge of the plateau he
saw the chaise at a distance, going towards the house. He made a
detour, so as to join the party from the rear, and reached them just
as the new domain was coming in sight.
“Look!” said his sister; “there’s a horseman in a great heat. Where
does he come from? Is it he who is directing the whole plot?”
“Certainly,” replied her mother. “Look!”
They were in fact just beginning to see the outlines of Paul’s
house, with its slated roof glistening in the rays of the sun. There
was silence, and, it must be confessed, a little emotion.
“I had my suspicions about it,” said Madame Marie, kissing her
mother and father. “And so during your painful experiences of last
year you were thinking of us so much as to have realized that project
of a house which I thought was only a fancy? And Paul!”
“Paul,” replied M. de Gandelau, “has had his share in the work,
and has contributed substantially to the success of the project. If he
ever becomes an architect you will have been the first cause of it.”
“And you, dear friend,” said Madame de Gandelau to her son-in-
law, who was kissing her hand tenderly, “you say nothing!”
“M. de Gandelau had written to me about it, and I was in the
secret. Marie can tell you whether I have kept it or not.”
“So we were betrayed, my poor Paul,” exclaimed his mother.
“M. de Gandelau wished to know whether settling in this
neighbourhood would not disconcert our plans for the future. I replied
to him that, on the contrary, it would further them; and that the only
cause which had hindered my building a house here after our
marriage was the fear of distressing you, and making you suppose
that we did not attach to your maternal hospitality the value it most
justly claims. Marie wishes to reside here a great part of the year;
she is known and beloved in this her native place; nothing could be
more agreeable to her than to follow your example—near to you,
almost under your eyes—without giving you the trouble which a
permanent residence in your house would have occasioned. I had no
need to consult her, for I knew that you were realizing a dream which
she was secretly cherishing, without hoping for its speedy
realization.”
“All is then for the best,” resumed Madame de Gandelau, looking
at her husband, for she was thinking of what she had said to him one
evening, two years before.
The family were received with vivats in front of the entrance steps.
Previous to entering the building, they went round it; and when they
came to the group of master-workmen and foremen, Paul introduced
them to his sister, saying that it was owing to their zeal, and their
desire to see her soon settled in the neighbourhood, that the
completion of the work in less than two years, was owing. Paul’s
compliment (which was neatly turned), but more particularly the
courteous bearing of his sister, who asked each what he had done,
inquired about their families, and expressed to them her wish to
employ them often, gained her the heart of these good people, who
for the most part had known her as a child.
 Madame Marie wanted to see everything. At each step
exclamations of joy were uttered, and Paul was embraced twenty
times by his “client.” Monsieur N—— had taken possession of
Eugène, who, we need scarcely say, was warmly congratulated.
M. Durosay did not fail to express his admiration every moment,
and was incessantly repeating, “It is a charming feudal manor-
house!”
“But, why, my dear sir,” said Madame Marie, at last quite weary of
the phrase, “Why do you call it a ‘manor-house,’ and ‘feudal’? I have
neither manor nor vassals, and I have no wish to possess any. Call it
a house, built for me by those who love me, and which will always be
open to our friends, and always accessible to those who may need
our help.”
We may be sure that Paul’s resolution to become an architect was
strengthened by what he felt on this occasion.
Let us hope that his career may be as successful as that of the
house whose history is here recorded.
 EXPLANATION
OF SOME OF THE TECHNICAL TERMS USED IN THIS
BOOK.

Barrel-vault (berceau de voûte), means a vault forming simply a

portion of a cylinder.
Basement (soubassement), part of a building which receives the
ground floor; that is to say, what is comprised between the floor
within and the ground without the building.
Bay-window (bretêche), a closed and covered balcony or loge,
having front and lateral views, forming a projection without and a
recess within. When supported on corbels it is termed an oriel.
Bearer (lambourde), piece of wood fixed horizontally against a
wall, and intended to receive the ends of the joists of a floor. The
term is also given to the strips of oak fastened on the plaster bed of
a floor, and on which are screwed the slabs of parquetry.
Bed (banc), the word bed, as a geological term, signifies a
homogeneous layer comprised between two natural horizontal beds
or fissures, supposing that the mass has not been deformed by an
upheaving. Limestones and some sandstones are extracted in beds.
Their thickness is very variable.
Bed-stones (libage), stone suitable for foundations.
Bed of the stone (lit de la pierre), is the upper, or under surface
of the layer. Bottom-bed is the term used to designate the under-
surface of a stone. Calcareous stones should be laid on their bed
just as they were in the quarry.
Blade, or Principal-rafter (arbalétrier), piece of timber
inclined, according to the slope of a roof, which is joined at the upper
end into the king-post, at its lower end into the tie-beam, and which
supports the purlins (see next page).
 Bond (harpe), projection formed by a dressed-stone for the
purpose of a tie into brick or stone-walling.
Broken-backed roof (bresis), a roof so called is one composed
of two planes of inclination, one of which is little and the other
considerably inclined. The dormer windows are generally opened in
the lower and more inclined plane.
Chimney-stack (souche de cheminée), is the part of the smoke-
shaft which surmounts the roofs, and is sometimes terminated with
pots of earthenware or of sheet metal.
Clip (moise), comparatively thin piece of timber, serving to
connect the parts of a framing by means of notches which hold them,
and of bolts. Clips are usually placed in couples.
Concrete (béton), a compound of lime, sand, and gravel rammed
in horizontal layers, and thus forming a compact and homogeneous
mass, which hardens more or less rapidly, according to the nature of
the lime; and on which the heaviest superstructure may be raised
without fear of cracks or settlements. In the making of concrete great
care and attention is always necessary, and a thorough
acquaintance with the nature of the lime made use of.
Corbel (corbeau), support of stone or wood projecting from the
face of a wall, having its front moulded or carved, its sides vertical
and carrying a beam, cornice, shaft, vault-springer, &c.
Elevation (élévation). By this word is designated in architecture
the geometrical view of a façade; properly speaking the vertical
projection.
Embankment (cavalier), heap of excavated earth, regularly placed
and raised above the surface of the ground.
Filleting (solin), weathering formed above a roof-covering and
following its slope against the walls which surmount it, to hinder the
rain from penetrating between the covering and the wall.
Foot-piece (blochet), piece of wood notched at right-angles on to
the wall-plates of a roof to receive the foot of the rafters, and the
foot-post, which hinders the rafter from sliding.
 Frame (dormant), fixed frame of wood, which receives the leaves
of a door or the opening casements of a window.
Gable (pignon), terminal part of a wall, which masks the timbering
of a roof and follows its slopes.
Hip (arêtier), exterior angle formed by the meeting of two roof-
surfaces on different planes.
Jamb (jambage), vertical side of a window or doorway. The term is
only applied to sides of masonry.
Joint (joint), vertical space left between two stones. It is called
dry-joint, when the stones are laid close-fitting, without mortar or
cement between them; and mortar-joint, when this interval is filled
with mortar.
Jointing (appareil), combination of worked stones.
Joist (solive), piece of wood laid horizontally to form flooring and
receive the plaster bed on which are laid the floor quarries or the
slabs of parquetry. Wood joists cannot, without bending, have a
bearing greater than 16 or 17 feet. Their strength and distance apart
are determined by their bearing and the weight they should sustain.
Joist-spaces (entrevous), intervals left between the joists of a floor.
Keeping account (attachement). By this is meant memoranda of
the work done or materials used on a building by means of written
notes or figures.
King-post (poinçon), vertical piece of wood, which in a principal
receives the two blades, and suspends the middle of the tie-beam.
Lintel (linteau), piece of timber or block of stone which, laid
across horizontally on the jambs of a door or window-opening,
completes the enclosure.
Made-ground (remblai). This term signifies earth and débris that
have been shifted by man to raise a piece of ground or fill up its
hollows.
Meeting-stile (battement), vertical stile of a door or of a
casement on the fastening side.
 Mortise (mortaise), oblong hole made in a piece of framing to
receive a tenon. The lengthways of a mortise should always follow
the grain of the wood.
Newel (noyau), pillar or column around which wind the steps of
the stairs.
Notching (embrèvement), sinking made in a piece of wood to
receive a mortise and tenon framing.
Pole (échasse), trunk of a tree, long and small, which, fixed up
perpendicularly, is employed for scaffolding buildings as they rise.
Post (poteau) vertical piece of wood, which on its head receives
one or more cross pieces. The term frame-post is applied to the
uprights of a framed partition, and especially those which serve as
door-frames.
Principal (ferme), framing of carpentry intended to carry the
covering of a roof.
Profile (profil), section of the member of a moulding of an
architectural detail.
Pugging (plâtras), filling-in of plaster work between the joists of a
floor or the uprights of a lath-and-plaster partition.
Purlin (panne), roofing-timber placed horizontally on the blade of
a principal and which carries the rafters.
Put-log (boulin), piece of wood which, resting in the wall at one
end, and upon the scaffold runners at the other, serves to carry the
platform upon which the men work in raising a building.
Rafter (chevron), piece of timber of small scantling, on which is
nailed the boarding or laths which receives the slates or tiles. In
good roofing rafters are placed 20 inches apart, centre and centre, at
most. They rest at bottom upon wall-plates, or upon foot-pieces, in
their length on the side-pieces or purlins, at their upper extremity
against the ridge-piece.
Rebate (feuillure), longitudinal sinking made in frames, posts, and
lintels, to receive doors and window-casements, &c.
 Ridge-pole (faîtage), horizontal piece of wood which, resting on
the top of the king-posts of the principals, forms the apex of the roof
and receives the rafters. The ridge-poles are supported in their
bearing, from one king-post to another, by struts.
Riser (contre-marche), the upright face of a step.
Scale of proportion (échelle de proportion). The text
sufficiently explains the use of the scale in architectural drawing,
rendering it needless to enlarge on the usefulness of this practical
method. By scale is also understood the relative proportions of an
edifice. Certain architectural members give the scale of the whole.
Thus, a balustrade ought not to exceed elbow height, nor fall short of
it; it then gives the scale of the building, that is to say, it indicates the
actual size of the whole, by taking for point of comparison the human
height.
Screw-bolts (boulon), round iron pin, with a square head at one
end, and a screw thread at the other, on which turns an iron nut,
serving to hold pieces of timber together.
Section (coupe), view of a building, or an architectural detail cut
through.
Sill (tableau), part of the casing of a door or window which comes
outside the enclosure.
Staircase (cage d’escalier), is the casing of masonry or timber-
work in which are enclosed the steps of the stairs.
Stile (montant), term in joinery applied to all upright pieces.
Strap (étrier), band of iron forming a stirrup, and passing beneath
the tie-beam of a principal, suspends it to the king-posts by means of
bolts.
Straight-tread (giron-droit), signifies a step of equal width all its
length; winding-tread, a step narrow towards the outer string, and
enlarging towards the wall of the staircase. It is said, the steps of the
stairs have a narrow tread when the width is small, and have a wide
tread when their width is large.
 String-board (crémaillère), piece of wood on which rests the
ends of the steps of the stairs, and which is grooved to ramp with
and receive the ends of the steps.
Strut (lien), slanting piece of wood connecting the blade to the
king-post of a principal, or a horizontal bearer to a post.
Tenon (tenon), tongue left at the end of a piece of framing, and
which fits into the end of the mortise.
Tie-beam (entrait), horizontal piece of timber, which receives at its
extremities the foot of the blades of a principal or truss, and which is
suspended in the middle by the king-post.
Tread (giron), is the width of a stair-step.
Tread (pas), is the level surface of a step on which the foot is
placed.
Trimmer (chevêtre), piece of wood which, framed into two
trimmer-joists, receives the ends of the joists, the space of the
hearth-stone from the fireplace, or across the openings of doors or
windows.
Trimmer-joist (solive d’enchevêtrure), stronger joist to receive
the trimmers in front of a hearth-stone or across a chimney-breast.
Valley (noue), interior angle, formed by the meeting of two planes
of roof.
Wall (mur). A gutter-wall is that which carries a gutter and
receives the eaves of a roof; a gable-wall that which closes in the
timber-work of a roof; a partition-wall that which within a building
divides the rooms—takes the bearing of the floors and the chimney-
flues.
Wall-face (parement), outer or inner surfaces of a wall.
Wall-plate (sablière), horizontal piece of wood laid on the top of
a wall lengthwise, and on which rest the tie-beams of the principals
and the feet of the rafters.
Water-bar (jet d’eau), projecting moulding affixed to the bottom
rail of window-casements and to the wood-sills, and contrived to
throw off the rain from the rebate, and from the junction of the wood-
sill with the stone-sill.

THE END.

LONDON: R. CLAY, SONS, AND TAYLOR, PRINTERS, BREAD STREET HILL.

 Transcriber’s Notes
pg 10 Changed: When his cousin was come
to: When his cousin had come
pg 10 Changed: architectural tyro to unrol again the paper
to: architectural tyro to unroll again the paper
pg 39 Changed: facts seem to rove that he
to: facts seem to prove that he
pg 49 Changed: successful result in this pacrticular case
to: successful result in this particular case
pg 50 Changed: it is easy to distingush the good
to: it is easy to distinguish the good
pg 78 Changed: by means of a plumb-lime
to: by means of a plumb-line
pg 183 Changed: Well, if you well let me have it for an hour
to: Well, if you will let me have it for an hour
*** END OF THE PROJECT GUTENBERG EBOOK HOW TO BUILD
A HOUSE ***

Updated editions will replace the previous one—the old editions will
be renamed.

Creating the works from print editions not protected by U.S.

copyright law means that no one owns a United States copyright in
these works, so the Foundation (and you!) can copy and distribute it
in the United States without permission and without paying copyright
royalties. Special rules, set forth in the General Terms of Use part of
this license, apply to copying and distributing Project Gutenberg™
electronic works to protect the PROJECT GUTENBERG™ concept
and trademark. Project Gutenberg is a registered trademark, and
may not be used if you charge for an eBook, except by following the
terms of the trademark license, including paying royalties for use of
the Project Gutenberg trademark. If you do not charge anything for
copies of this eBook, complying with the trademark license is very
easy. You may use this eBook for nearly any purpose such as
creation of derivative works, reports, performances and research.
Project Gutenberg eBooks may be modified and printed and given
away—you may do practically ANYTHING in the United States with
eBooks not protected by U.S. copyright law. Redistribution is subject
to the trademark license, especially commercial redistribution.

START: FULL LICENSE

THE FULL PROJECT GUTENBERG LICENSE
 PLEASE READ THIS BEFORE YOU DISTRIBUTE OR USE THIS WORK

To protect the Project Gutenberg™ mission of promoting the free

distribution of electronic works, by using or distributing this work (or
any other work associated in any way with the phrase “Project
Gutenberg”), you agree to comply with all the terms of the Full
Project Gutenberg™ License available with this file or online at
www.gutenberg.org/license.

Section 1. General Terms of Use and

Redistributing Project Gutenberg™
electronic works
1.A. By reading or using any part of this Project Gutenberg™
electronic work, you indicate that you have read, understand, agree
to and accept all the terms of this license and intellectual property
(trademark/copyright) agreement. If you do not agree to abide by all
the terms of this agreement, you must cease using and return or
destroy all copies of Project Gutenberg™ electronic works in your
possession. If you paid a fee for obtaining a copy of or access to a
Project Gutenberg™ electronic work and you do not agree to be
bound by the terms of this agreement, you may obtain a refund from
the person or entity to whom you paid the fee as set forth in
paragraph 1.E.8.

1.B. “Project Gutenberg” is a registered trademark. It may only be

used on or associated in any way with an electronic work by people
who agree to be bound by the terms of this agreement. There are a
few things that you can do with most Project Gutenberg™ electronic
works even without complying with the full terms of this agreement.
See paragraph 1.C below. There are a lot of things you can do with
Project Gutenberg™ electronic works if you follow the terms of this
agreement and help preserve free future access to Project
Gutenberg™ electronic works. See paragraph 1.E below.
1.C. The Project Gutenberg Literary Archive Foundation (“the
Foundation” or PGLAF), owns a compilation copyright in the
collection of Project Gutenberg™ electronic works. Nearly all the
individual works in the collection are in the public domain in the
United States. If an individual work is unprotected by copyright law in
the United States and you are located in the United States, we do
not claim a right to prevent you from copying, distributing,
performing, displaying or creating derivative works based on the
work as long as all references to Project Gutenberg are removed. Of
course, we hope that you will support the Project Gutenberg™
mission of promoting free access to electronic works by freely
sharing Project Gutenberg™ works in compliance with the terms of
this agreement for keeping the Project Gutenberg™ name
associated with the work. You can easily comply with the terms of
this agreement by keeping this work in the same format with its
attached full Project Gutenberg™ License when you share it without
charge with others.

1.D. The copyright laws of the place where you are located also
govern what you can do with this work. Copyright laws in most
countries are in a constant state of change. If you are outside the
United States, check the laws of your country in addition to the terms
of this agreement before downloading, copying, displaying,
performing, distributing or creating derivative works based on this
work or any other Project Gutenberg™ work. The Foundation makes
no representations concerning the copyright status of any work in
any country other than the United States.

1.E. Unless you have removed all references to Project Gutenberg:

1.E.1. The following sentence, with active links to, or other

immediate access to, the full Project Gutenberg™ License must
appear prominently whenever any copy of a Project Gutenberg™
work (any work on which the phrase “Project Gutenberg” appears, or
with which the phrase “Project Gutenberg” is associated) is
accessed, displayed, performed, viewed, copied or distributed: